title: Mozambique Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/mozambique/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Mozambique MZ schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 72 sourced findings · 160 sources in the cumulative register 14 Modules baseline.modules[] 72 Findings modules[].findings[] 65 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Banco de Moçambique's Aviso n.º 7/GBM/2026, de 1 de Outubro extends the exceptional foreign-exchange export-earnings conversion regime, under which 50 percent of foreign-currency receipts must be converted, for a further six months from 9 October 2026. The notice gives no detailed justification beyond stating the need to extend the period, but the central bank's governor has separately pointed to FX purchase volumes as grounds for caution about claims of a structural foreign-currency shortage: up to August 2026, the banking system purchased USD 5,730 million in foreign currency from exporters and other economic agents, USD 724 million more than the same period the prior year. The extension signals that the exceptional regime, originally framed as temporary, continues to be treated by the central bank as necessary to the operating environment for cross-border payment flows in and out of Mozambique. #### Other Developments **National Payment System supervisory architecture now has a dedicated statutory basis.** Lei n.º 15/2026 formally designates Banco de Moçambique as the National Payment System authority, with powers to license operators, regulate, inspect and supervise all infrastructures, service providers and other sector participants. Payment-system operators, service providers and participants must register with and submit to licensing, inspection and supervision by the central bank, and breaches carry fines of up to 1,500 minimum wages. This architecture has been in force since August 2026 and represents a material consolidation of regulatory authority over the payments sector under a single statutory instrument, applicable to both bank and non-bank participants. **The same payments law extends legal recognition to distributed-ledger technology for securities-account operations.** Lei n.º 15/2026 grants legal recognition to distributed-ledger technologies, including blockchain, for opening, maintaining and settling securities-account-related operations, and empowers Banco de Moçambique to establish regulatory sandboxes for financial innovation and inclusion. This is a payments-infrastructure provision embedded within the general National Payment System law, not a stablecoin-specific or digital-money-specific regime in its own right. #### Cross-Monitor Connections The FX conversion regime extension and the National Payment System law both bear on Mozambique's broader financial-integrity posture, which separately tracks a structural registration and reporting gap among real-estate obliged entities and a related recommendation for an integrated property-transfer database; cash-based and cross-border fund flows implicated in that gap intersect with the currency-conversion and payment-supervision architecture described here, though the two developments were sourced independently this period. The DLT recognition provision also connects to the crypto monitor's tracking of Banco de Moçambique's separate virtual-asset-service-provider registration requirement under Aviso n.º 4/GBM/2023, though the two instruments serve different legal purposes and are not to be conflated. #### Outlook The FX conversion regime's six-month extension from 9 October 2026 sets the next natural review point in the first half of 2027, when the central bank will need to decide whether to extend the exceptional measure again or allow it to lapse; the governor's citation of rising FX purchase volumes suggests the central bank may be laying groundwork for eventually easing the measure, though no such decision has been made. On the payments-architecture side, the National Payment System law's licensing and supervisory powers, in force since August 2026, are likely to generate further developments as Banco de Moçambique begins exercising its registration and inspection authority over the full range of payment-system participants now brought within its remit, including any entities engaging with the newly recognised DLT-based securities-settlement mechanism. _7 earlier updates not shown here._ ###### Standing brief · as of 11 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Mozambique's central bank launched the country's first domestic instant-payment rail this cycle, and the launch reshapes who sits inside the formal payments perimeter. The Mozambique Instant Payment System, marketed as METIX, went live on 16 March 2026 in Matola as a 24/7/365 retail rail, with daily transaction limits set at 200,000 meticais for individuals and 500,000 meticais for legal entities. Its regulatory foundation, Notice No. 1/GBM/2026, makes participation mandatory not only for credit institutions but for electronic money institutions and Banco de Moçambique-authorised digital wallet operators alike. That mandatory inclusion of non-bank e-money issuers alongside banks is the analytical hinge of this cycle: it extends real-time settlement access to the mobile-money layer that already carries the bulk of retail transaction volume in the country. The same Notice frames SPIM explicitly as a vehicle for digitalisation, financial inclusion and innovation within the financial system, tying the infrastructure launch to Banco de Moçambique's broader National Financial Inclusion Strategy 2025-2031. Yet the inclusion of e-money institutions in a real-time settlement mandate throws into relief a gap sitting one layer beneath it: Mozambique's formal Deposit Guarantee Fund, established via Decree 36/2024 and its accompanying ministerial diplomas, protects bank depositors, but no equivalent float-segregation or safeguarding regime for e-money customer funds was identified in the sources reviewed this cycle. Non-bank issuers are being pulled deeper into the payments core through participation mandates while the customer-protection architecture underneath them remains less codified than the bank-deposit analogue. That asymmetry between inclusion in market infrastructure and inclusion in protection infrastructure is the throughline for how Mozambique's payments formalisation is unfolding in 2026. #### Other Developments The single largest financial-integrity event on Mozambique's calendar this cycle is not a new signal but a resolution of an old one. The "tuna bonds" hidden-debt scandal moved through decisive stages: a 2024 English High Court judgment substantially favoured Mozambique and produced a US$3.1 billion award against Privinvest, while Credit Suisse and its subsidiary CSSEL resolved the matter for US$547 million as part of a roughly US$500 million-plus coordinated global settlement, and former finance minister Manuel Chang was convicted in the United States in 2024. In parallel, Banco de Moçambique's own domestic enforcement machinery continued to run: nine institutions were fined between December 2023 and December 2024 under Law 20/2020 and Law 11/2022, with further late-2025 fines against FNB Mozambique, Banco Letshego, BIM and MyBucks. Together the two strands - international litigation crystallising accountability for the 2016 hidden-debt affair, and an active domestic sanctions regime for prudential, AML/CFT, forex and consumer-protection breaches - describe a regulator and judiciary willing to enforce, not merely legislate. Operational resilience also moved this cycle. Parliament unanimously approved a Cybersecurity Law in April 2026, and Critical Information Infrastructure mapping and business-impact assessments are now under way with World Bank support. The reform carries an explicit historical justification: a 2018 vendor-licensing dispute triggered a nationwide blackout of the SIMORede payment system that left hospitals, schools and businesses unable to process electronic payments. That episode remains the reference point motivating current third-party and vendor-dependency resilience work, even though no date has yet been set for the pending legal framework that will designate CII operators and their proportionate obligations. Scheme-level friction persists alongside the new instant-payment rail. SIMO, operated with Euronet, runs the national card and payment switch and has been migrating away from the legacy SIMOrede platform since 2018/2023; Visa holds over 90% of card acceptance share, but the migration has caused recurring Mastercard acceptance disruption. On market structure, three banks - Millennium BIM, BCI and Standard Bank - hold more than 70% of banking assets, yet mobile-wallet accounts (24.6 million) outnumber bank accounts (6.6 million) by a wide margin, confirming a usage pattern dominated by mobile money even where balance-sheet concentration sits with banks. Physical acceptance infrastructure contracted slightly over the same period, with POS terminals falling from 35,470 to 33,191 and ATMs from 1,413 to 1,399 in the year to November, even as digital-wallet usage keeps expanding. On licensing and product innovation, Banco de Moçambique's single-regulator model - licensing credit institutions, financial companies, microfinance operators and EMIs itself under Law No. 20/2020 as regulated by Decree 50/2024 - continued to run its seventh Regulatory Sandbox edition, framed within the National Financial Inclusion Strategy 2025-2031 and inviting fintechs and aggregators to work on inclusive digitalisation, consumer protection and green finance themes. Consumer-facing friction, meanwhile, is concentrated and unremarkable in kind: roughly 45% of complaints concern ATM funds debited but not dispensed, handled directly within Banco de Moçambique's own conduct-supervision function in the continued absence of a dedicated financial-consumer protection agency. On the commercial side, Mozambique's fintech base remains thin but not inert: Kuunda expanded into the market on the back of a US$7.5 million pre-Series A round intended to accelerate growth across Africa and the Middle East, Roscas secured an undisclosed-amount investment from Renew Capital, and a EUR 33.5 million KfW-funded agribusiness credit line (FINOVA) was announced under the Ministry of Planning and Development. #### Cross-Monitor Connections Two threads in this cycle's Mozambique findings carry analytical content beyond payments-market scope and are flagged to FIM rather than resolved here. First, Mozambique's removal from the FATF grey list in October 2025, after completing all 26 action-plan items alongside South Africa, Nigeria and Burkina Faso, and Banco de Moçambique's imposition of tiered transaction and balance limits on e-money institutions - citing a "high" terrorism-financing threat assessment tied to fund movement into areas of active terrorist activity via rural IME concentration - are carried here purely on Sentinel.gi provenance; the underlying illicit-finance analysis sits with FIM, not WPM. Second, the tuna-bonds affair itself involves bribery, embezzlement and sovereign-debt fraud dimensions that extend well beyond WPM's payments and market-structure remit; this brief treats the litigation and settlement outcomes only as they bear on Mozambique's payments-sector legal and reputational environment. #### Outlook The direction of travel across this cycle's findings is toward formalisation and liberalisation running on several tracks at once - instant payments, cybersecurity legislation, and improved cross-border standing following the FATF delisting - while conduct and safeguarding architecture for non-bank e-money issuers still lags the bank-centred baseline. Banco de Moçambique's National Financial Inclusion Strategy 2025-2031 is expected to reach the end of its first phase around 2027, and that horizon marker will be the natural point at which to assess whether SPIM/METIX participation, sandbox output and consumer-protection reform have converged into a coherent non-bank framework or left the safeguarding gap unresolved. In the near term, watch for the pending CII-operator legal framework flowing from the new Cybersecurity Law, for further SIMO/Euronet migration-related acceptance disruption, and for whether Banco de Moçambique's active sanctions cadence extends to new categories of institution as SPIM participation broadens the population of supervised entities. trust tier: ai_unverified ###### Latest update · 18 October 2026 #### Regulatory Status Mozambique's payments-regulatory environment registered two material developments this period. First, Banco de Moçambique extended its exceptional foreign-exchange export-earnings conversion regime, requiring 50 percent conversion of foreign-currency receipts, for a further six months from 9 October 2026, under Aviso n.º 7/GBM/2026. Second, Lei n.º 15/2026, in force since August 2026, formally designates Banco de Moçambique as the National Payment System authority, with licensing, regulatory, inspection and supervisory powers over all payment infrastructures, service providers and participants, backed by fines of up to 1,500 minimum wages for breach, and applicable to both bank and non-bank participants. The same law also grants legal recognition to distributed-ledger technology for securities-account operations and empowers the central bank to create regulatory sandboxes for financial innovation. Taken together, these developments show a central bank simultaneously tightening its grip on foreign-currency flows through an extended exceptional measure, and consolidating its formal regulatory authority over the payment-services sector through a new statutory licensing and supervisory framework. The central bank governor's public citation of rising FX purchase volumes, even as the exceptional conversion regime continues, is a notable internal tension in the current regulatory posture. #### Outlook The FX conversion regime's next review point falls in the first half of 2027. On the licensing side, the period ahead is likely to surface the first concrete exercises of Banco de Moçambique's new National Payment System supervisory authority, including possible early sandbox activity under the DLT-recognition and innovation-sandbox powers granted by the same law. _3 earlier updates not shown here._ ###### Standing brief · as of 11 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Mozambique enters World Payments Monitor coverage this cycle as a baseline jurisdiction, with sourced findings across all fourteen modules of the analytical spine. The core regulatory architecture is bank-centric and single-regulator: Banco de Moçambique licenses and supervises credit institutions, financial companies, microfinance operators and electronic money institutions under Law No. 20/2020 as regulated by Decree 50/2024, and separately requires virtual-asset service providers to register (not licence) under Aviso No. 4/GBM/2023. The same regulator runs market-conduct supervision directly, via Notices 8/GBM/2021 and 9/GBM/2020, and a formal Deposit Guarantee Fund protects bank depositors, though no equivalent e-money safeguarding regime for IME customer funds was identified. The most significant infrastructure development is the March 2026 launch of the Mozambique Instant Payment System (SPIM/METIX), whose governing Notice 1/GBM/2026 makes participation mandatory for EMIs and BdM-authorised digital wallet operators alongside credit institutions - extending real-time settlement access to the mobile-money layer that already carries the bulk of transactional usage: 24.6 million mobile-wallet accounts against 6.6 million bank accounts, even as three banks hold over 70% of banking-sector assets. Card-scheme migration (SIMO/Euronet, replacing legacy SIMOrede) continues to generate recurring Mastercard acceptance disruption despite Visa's dominant share, and physical POS/ATM infrastructure has contracted slightly even as digital-wallet usage surges. On resilience, Parliament approved a new Cybersecurity Law in April 2026 and CII mapping is under way, motivated in part by the 2018 SIMORede blackout precedent. On cross-border standing, Mozambique was removed from the FATF grey list in October 2025 after completing all 26 action-plan items, materially improving its correspondent-banking risk profile, even as global de-risking has cut correspondent relationships by 15-20% across Africa since 2010 and the formal South Africa-Mozambique remittance corridor has contracted 36% since 2022. Mozambique's principal cross-border settlement channel remains SADC-RTGS, joined in October 2016. Legally, the tuna-bonds hidden-debt scandal reached decisive milestones (a US$3.1bn award against Privinvest and a US$547m Credit Suisse global settlement), while Banco de Moçambique's own domestic sanctions regime continues to fine institutions for prudential, AML/CFT, forex and consumer-protection breaches. Consumer complaints are handled directly by BdM, dominated by ATM non-dispense disputes, absent a dedicated consumer agency or APP-fraud reimbursement rule. Commercially, the fintech base remains nascent, marked by Kuunda's pre-Series A round and Roscas' Renew Capital investment. #### Outlook Mozambique's overall regulatory trajectory this cycle is liberalising and formalising: FATF delisting, the new instant-payment rail, and the Cybersecurity Law together signal a jurisdiction moving from a historically thin resilience and cross-border risk position toward a more structured one. The principal unresolved tension is that inclusion of non-bank e-money issuers in core payments infrastructure (SPIM participation) is running ahead of a corresponding codification of non-bank customer-fund safeguarding. The National Financial Inclusion Strategy 2025-2031's first phase, expected to conclude around 2027, is the natural horizon marker for assessing whether that gap closes. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Probable confirmed 2026-07-04 Bank of Mozambique is reaffirmed as central licensing/supervisory authority for the National Payment System under Lei n.º 15/2026, de 2 de Julho, which repeals Lei n.º 2/2008 and gives incumbent operators 180 days to register. Bank of Mozambique granted cross-border PSP PawaPay a licence to onboard merchants directly (8 Oct 2026). Standing sub-brief · as of 11 August 2026 346 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Banco de Moçambique operates as Mozambique's sole licensing and prudential authority across the banking and near-banking space. Credit institutions, financial companies, microfinance operators and electronic money institutions are all authorised and supervised under the same statute, Law No. 20/2020, as further regulated by Decree 50/2024, with Article 16 of the Law vesting case-by-case incorporation authorisation directly in the BdM Governor via the Regulation and Licensing Department. There is no separate licensing track for non-bank payment or e-money activity distinct from the bank-centred regime; EMIs sit inside the same authorisation architecture as credit institutions and financial companies, differentiated by prudential category rather than by a separate non-bank licensing gateway. This is a genuinely bank-centric, single-regulator model, in contrast to jurisdictions that run parallel EMI/PI licensing regimes outside the banking authorisation track. The one area where Banco de Moçambique has built a distinct, lighter-touch gateway is virtual-asset activity. Under Aviso No. 4/GBM/2023, virtual-asset service providers are required to register - not obtain a full licence - in a centralised state register, with a 90-day review period, a unique ID issued per registrant, and revocable registration status. This registration regime is analytically separate from the Law 20/2020 licensing track: it creates a state visibility mechanism over VASPs without folding them into the credit-institution/financial-company/EMI licensing perimeter. That said, this registration-regime claim rests on a single T4 (vendor/law-firm) source this cycle and was not independently corroborated by a T1/T2 anchor, so it should be read as assessed rather than confirmed detail pending further corroboration. #### Outlook Because sub-national divergence is not a live consideration in Mozambique's unitary, BdM-centralised licensing structure, the module's forward risk sits almost entirely in how the VASP registration regime evolves relative to the core Law 20/2020 licensing track, and in whether Notice 1/GBM/2026's extension of mandatory instant-payment-system participation to EMIs and BdM-authorised wallet operators (see W4/W5) is followed by any adjustment to the underlying licensing categories themselves. No such adjustment has been identified in current sources; the licensing architecture is the established baseline against which subsequent scheme and product mandates are being layered. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Lei n.º 15/2026 formally designates Banco de Moçambique as the National Payment System authority for Mozambique, with powers to license operators, regulate, inspect and supervise all payment infrastructures, service providers and other sector participants. This is a consolidating statutory development: rather than fragmented or informal oversight, payment-system operators, service providers and participants are now required to register with and submit to licensing, inspection and supervision by the central bank as a matter of law. Breach of these requirements carries fines of up to 1,500 minimum wages, giving the licensing regime a defined penalty structure from the outset. The law applies to both bank and non-bank participants in the payment system, meaning the licensing and supervisory perimeter is not limited to traditional deposit-taking institutions but extends across the payment-service-provider landscape more broadly. The law has been in force since August 2026, roughly two months ahead of this reporting window, giving Banco de Moçambique an established statutory basis from which to begin exercising its licensing, inspection and supervisory powers over the sector it now formally oversees. No information was available this period on how many entities have been licensed or registered under this new authority since August 2026, nor on any enforcement action taken under the fine provisions. The full pinpoint statutory text of Lei n.º 15/2026 was not retrieved this period, so finer details of the licensing application process, conditions, and categories of regulated participant beyond the general authority grant remain to be confirmed. #### Outlook The item to watch is how Banco de Moçambique begins to exercise its newly consolidated licensing and supervisory authority in practice: which categories of payment-service provider are brought under active registration first, and whether any enforcement action under the 1,500-minimum-wage fine provision materialises. Given the law's in-force status since August 2026, the period ahead is likely to surface the first concrete applications of this authority. **5 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Mozambique's licensing and market-access landscape shifted structurally this cycle with the enactment of Lei n.º 15/2026, of 2 July, which establishes a new legal regime for the National Payment System and repeals the prior 2008 law. The new law requires incumbent payment-system operators to register with the Bank of Mozambique within 180 days of entry into force, a registration obligation rather than a full re-licensing exercise, but one that nonetheless compels every existing operator to actively re-present itself under the new framework. The practical deadline for that registration falls at the close of 2026, meaning the coming months will determine which incumbent operators remain formally on record under the revised regime. Alongside this structural reset, the Bank of Mozambique granted a payment-services-provider licence to PawaPay, a cross-border payments aggregator, in an event dated 8 October 2026. The licence permits PawaPay to onboard merchants directly onto mobile-money rails rather than requiring intermediation through an existing bank or mobile-network operator. Reporting indicates M-Pesa connectivity is already live and e-Mola is enabled for payouts, while Tmcel's mKesh wallet remains unconnected. No Bank of Mozambique primary notice confirming the licence grant has been located; the finding rests on corroborating secondary and tertiary press reporting. Taken together, these two developments describe a market-access environment in active transition: a wholesale legal reset of the registration regime for payment-system operators generally, occurring in parallel with a specific new market entrant gaining direct access to the country's dominant payments rail. For incumbent operators, the near-term task is compliance with the registration deadline; for new entrants such as PawaPay, the opportunity is direct merchant-facing access to a market where mobile-money penetration substantially exceeds traditional banking penetration. #### Outlook The registration deadline under Lei n.º 15/2026, falling at the close of 2026, is the key date to track for this module: it will reveal both how many incumbent operators successfully transition to the new regime and whether the Bank of Mozambique applies any substantive review during what is nominally a registration rather than re-licensing process. Separately, whether PawaPay's merchant-onboarding activity extends to a connection with Tmcel's mKesh wallet would materially expand the addressable mobile-money base available to the aggregator under its new licence. Periodic update · new data 2026-09-29 #### Licensing, Authorisation & Market Access Mozambique has enacted Law 15/2026, replacing the 2008 National Payment System Law and establishing a new legal foundation for payment-system licensing and market access. Existing payment-system operators have a 180-day window from the law's approval to adapt to the new requirements. Notably, the transition mechanism for incumbents is registration with Banco de Moçambique rather than a fresh licensing round: operators already active in the market are exempt from initial licensing under the new law, but must complete registration within the adaptation window to remain compliant. This is a market-access-defining change rather than an incremental update: it replaces the entire prior statutory basis for payment-system operation in Mozambique. For new entrants, this signals that the operative legal text governing licensing has changed, and any market-entry assessment should be conducted against Law 15/2026 rather than the superseded 2008 law. For incumbents, the registration requirement is a lighter-touch transition than full relicensing, but it remains a mandatory compliance step with a defined and immediate deadline. Carrying the bank-PSP versus non-bank payment-institution distinction forward, the available evidence this cycle does not specify whether Law 15/2026 differentiates registration or licensing treatment between bank-affiliated payment-system operators and non-bank payment institutions or e-money issuers; this is a gap in the current evidence base rather than a confirmed absence of such differentiation. #### Outlook The close of the 180-day adaptation window is the key near-term marker for this module: it will indicate how comprehensively the existing operator base has completed registration under Law 15/2026. Any further implementing regulations, circulars, or Banco de Moçambique guidance clarifying registration procedure or differentiated treatment by operator type would be the next material development to track. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Mozambique enacted Law 15/2026, establishing a wholly new legal regime for the National Payment System and repealing the prior Law No. 2/2008. Banco de Moçambique is reaffirmed as the central licensing, inspection and supervisory authority for the payments sector under this new instrument. Existing payment-system operators are given a 180-day window to adapt to and register under the new law; the transition arrangements exempt incumbents from an initial fresh licensing process, but registration with Banco de Moçambique is still required. This is a confirmed, T1-anchored legislative reset of the market-access framework, corroborated by contemporaneous press reporting on the transition mechanics, and it applies across both bank and non-bank payment-system operators rather than to a single category of entity. The practical effect for market participants is a defined compliance clock: operators already active under the repealed 2008 regime must complete registration within 180 days or fall outside the new legal perimeter, while new entrants presumably face the licensing pathway the new law establishes, though the specific licensing-category mechanics beyond the incumbent-transition provision were not detailed in this cycle's findings. The reform sits alongside, and is likely connected in intent to, the concurrent launch of the instant-payment infrastructure described under Operational Resilience below: a market-access reset paired with a new settlement rail suggests a coordinated modernisation push by Banco de Moçambique rather than two unrelated initiatives. No enforcement action, licence revocation, or specific operator-level licensing decision was identified this cycle under this module; the finding is confined to the legislative reset itself and its transition terms. #### Outlook The marker to track is the close of the 180-day registration window opened by Law 15/2026, which will indicate how many existing payment-system operators have formally transitioned into the new legal regime, and whether any fail to register within the deadline. Any subsequent Banco de Moçambique guidance detailing new-entrant licensing categories or conditions under the new regime would materially extend this finding and should be watched for in the next cycle. Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access Banco de Moçambique's Notice/Aviso 1/GBM/2026, dated 25 February 2026, established the Mozambique Instant Payment System (SPIM) and approved its Regulation, entering into force 2 March 2026. This is a high-confidence, T1 primary-regulator finding. SPIM is operated by SIMO under a new technology platform branded METIX, which integrates commercial banks and mobile-wallet operators — M-Pesa, e-Mola and m-Kesh — onto a single real-time settlement platform, officially launched 16 March 2026. The market-access significance of this development is best understood against Mozambique's account-holding structure: as of November 2025, mobile-wallet accounts numbered over 24.6 million against 6.6 million traditional commercial-bank accounts. SPIM's architecture is mandatory for licensed banks, microbanks and IMEs alike, meaning the market-access question for new entrants shifts from whether to obtain a banking or e-money licence toward whether that licence carries automatic SPIM participation rights under the new Regulation. The bank-PSP vs non-bank IME distinction is carried directly into this framework: both categories connect to the same METIX rail, but under access terms defined by their respective licensing category rather than a converged single licence type. #### Outlook Watch for confirmation of participation terms and technical-access requirements for non-bank IMEs relative to licensed banks under the SPIM Regulation, and for whether additional mobile-wallet operators beyond M-Pesa, e-Mola and m-Kesh are onboarded to METIX in subsequent cycles. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Banco de Mocambique's Aviso No. 1/GBM/2026, effective 2 March 2026, establishes the Mozambique instant payment system, branded SPIM or its operational name METIX, and designates SIMO as the operating entity. This is a Tier 1 primary-source development, carrying high confidence, and it sits squarely within the licensing and market-access perimeter because participation is mandatory rather than optional: credit institutions, payment service providers, and other Banco de Mocambique-authorised entities are all brought within the scheme's participation requirement. This mandatory design is the single most consequential market-access fact in the notice, because it forecloses the possibility of a two-tier market in which only banks connect to the new real-time rail while non-bank payment service providers remain on legacy bilateral arrangements. Both categories of institution face the same connectivity obligation, which is a materially different starting position from jurisdictions where instant-payment participation is bank-led with non-bank access following later, or mediated through indirect participation via a sponsoring bank. The scheme's initial operating parameters, reported at Tier 3 confidence via Club of Mozambique's coverage of the launch, set a daily transaction limit of 200,000 MZN, approximately USD 3,129, for individual transfers, with higher limits available to legal entities. Interbank individual transactions are exempt from fees under the initial parameter set. This fee-exemption choice is a market-access-shaping decision in its own right: it lowers the cost of switching from existing payment rails to SPIM for retail users specifically, which is consistent with a regulator-operator strategy of building transaction volume during the scheme's early adoption phase before introducing commercial pricing tiers. A second material licensing and market-access development this cycle is Banco de Mocambique's Aviso No. 2/GBM/2026, dated 2 June 2026, which establishes new connection rules for the Rede Unica de Pagamentos, the country's shared payments network, and explicitly revokes the prior Aviso No. 2/GBM/2015. This is a Tier 1 primary-source development sourced directly from the BdM normativos register, carrying high confidence. The revocation of a decade-old connection-rules instrument in favour of a new framework, arriving three months after the SPIM launch, reads as a coordinated modernisation of the underlying network architecture rather than an isolated administrative housekeeping change. Because Rede Unica is the shared network underlying broader retail payments access in Mozambique, a reset of its connection rules is itself a market-access event. The interpreter record available this cycle does not itemise the specific participant-category detail, bank versus non-bank, for the revised connection rules, which is a gap worth closing in the next review cycle. The bank-versus-non-bank distinction is worth stating explicitly for this module: Mozambique's mobile-money-led retail payments market has historically been dominated by non-bank electronic-money issuers operating alongside, rather than fully integrated with, the bank-centred settlement infrastructure. SPIM's mandatory-participation design changes that structural picture by placing both categories under a single real-time settlement obligation, which is a more integrated market-access model than a bank-only instant-payments scheme would produce. Both instruments took effect within a single calendar year, Aviso 1/GBM/2026 in March and Aviso 2/GBM/2026 in June, a fast implementation cadence relative to typical central-bank payments-infrastructure programmes, though the interpreter record does not identify any specific technical-assistance provider this cycle. #### Outlook The most consequential open question for market access is how quickly non-bank payment service providers achieve practical, not just nominal, connectivity to SPIM, given that the mandatory-participation requirement establishes the obligation but does not by itself guarantee uniform technical readiness across a diverse population of banks and PSPs. A second item to track is whether Banco de Mocambique publishes further implementing guidance on the Rede Unica connection-rules reset that clarifies participant categories and technical connection standards. Both developments should be read together as a single modernisation programme whose market-access implications will become clearer as implementation deepens. **1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-09-08 #### Regulatory Landscape & Supervising Authority Banco de Moçambique underwent a leadership transition in early September 2026. Felisberto Dinis Navalha was sworn in as Governor, succeeding Rogério Zandamela, whose second and final five-year term as Governor concluded. Benedita Maria Guimino was sworn in concurrently as Vice-Governor. The appointment followed a rapid reversal: President Chapo revoked his initial appointment of Waldemar Fernando de Sousa as Governor less than a day after announcing it, before Navalha was installed. The transition is a governance-continuity event; Banco de Moçambique's prudential and conduct architecture for the payments sector, anchored in Law No. 20/2020 and its implementing Decree No. 50/2024, is not reported to have changed as a result. Separately, Banco de Moçambique opened the call for the eighth edition of its Regulatory Sandbox, continuing its innovation-policy engagement with bank and non-bank payment-service providers under the new leadership. #### Outlook The leadership change carries elevated near-term attention given its unusual sequencing, but the analytical baseline is continuity rather than disruption: the supervisory architecture applicable to both bank and non-bank payment institutions in Mozambique is unchanged, and the Regulatory Sandbox call signals continued openness to innovation-track engagement under the new Governor and Vice-Governor. **Sources and findings (7)** 1. T1 [https://www.bancomoc.mz/en/areas-of-expertise/licensing/licensing-of-institutions/](https://www.bancomoc.mz/en/areas-of-expertise/licensing/licensing-of-institutions/) retrieved 2026-07-04 2. T1 [https://www.bancomoc.mz/en/areas-of-expertise/licensing/licensing-of-institutions/](https://www.bancomoc.mz/en/areas-of-expertise/licensing/licensing-of-institutions/) retrieved 2026-07-04 3. T2 [https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique) retrieved 2026-07-04 4. T2 [https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique) retrieved 2026-07-04 5. T3 [https://www.mozambiqueexpert.com/en/mozambiqu-mobile-money-operators-mmo/](https://www.mozambiqueexpert.com/en/mozambiqu-mobile-money-operators-mmo/) retrieved 2026-07-04 6. T4 [https://incfine.com/en/obtaining-a-crypto-license-in-mozambique/](https://incfine.com/en/obtaining-a-crypto-license-in-mozambique/) retrieved 2026-07-04 7. T3 [https://www.mozambiqueexpert.com/en/mozambique-banking-sector/](https://www.mozambiqueexpert.com/en/mozambique-banking-sector/) retrieved 2026-07-04 ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-07-04 BdM directly supervises market conduct of all credit institutions, financial companies and IMEs via Notices (e.g. 8/GBM/2021 on contractual terms/transparency, 9/GBM/2020 on complaints handling) issued under Law 20/2020. Depositor protection runs through a formal Deposit Guarantee Fund (FGD) established in 2024, though a dedicated EMI-specific safeguarding/segregation regime for e-money float remains less codified than the bank-deposit regime. Standing sub-brief · as of 4 July 2026 280 words · last cycle 2026-07-04 #### Conduct, Safeguarding & Financial Promotions Market conduct across Mozambique's credit institutions, financial companies and IMEs is directly supervised by Banco de Moçambique itself, under Notices issued pursuant to Law 20/2020 - Notice 8/GBM/2021 on contractual terms and transparency, and Notice 9/GBM/2020 on complaints handling. There is no separate conduct authority distinct from the prudential regulator; BdM performs both roles for the same set of regulated entities, spanning bank and non-bank e-money issuers alike. Depositor protection, however, is structured asymmetrically between the two categories. A formal Deposit Guarantee Fund (FGD) was established via Decree 36/2024 and Ministerial Diplomas 85/2024 and 86/2024, giving bank depositors a codified guarantee mechanism. No equivalent e-money float-segregation or safeguarding regime for IME/EMI customer funds was identified in the sources reviewed this cycle - the protection architecture for bank deposits is formal and recent, while the analogous protection for non-bank e-money balances remains, on current evidence, less codified. Given that Notice No. 1/GBM/2026 (see W4/W5) simultaneously makes instant-payment-system participation mandatory for EMIs and wallet operators, this is a live asymmetry: non-bank issuers are being drawn further into core payments infrastructure while the customer-fund protection layer beneath them has not visibly kept pace with the bank-deposit analogue. #### Outlook The safeguarding gap identified this cycle is the module's central forward-looking question. As mobile-wallet participation in real-time payments scales under SPIM/METIX, the absence of a dedicated e-money safeguarding regime becomes more consequential in proportion to the value flowing through non-bank rails. Whether Banco de Moçambique addresses this through an EMI-specific instrument, or through an extension of FGD-style protection, is not yet indicated in the sources reviewed and should be treated as an open regulatory question rather than a settled trajectory. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T1 [https://www.bancomoc.mz/en/areas-of-expertise/supervision/conduct/](https://www.bancomoc.mz/en/areas-of-expertise/supervision/conduct/) retrieved 2026-07-04 2. T1 [https://www.bancomoc.mz/en/areas-of-expertise/supervision/conduct/](https://www.bancomoc.mz/en/areas-of-expertise/supervision/conduct/) retrieved 2026-07-04 3. T2 [https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique) retrieved 2026-07-04 4. T2 [https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/mozambique) retrieved 2026-07-04 5. T2 [https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Mozambique-Diagnostic-Review---Banking-and-Non-Banking-Credit-Institutions---V-II.pdf](https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Mozambique-Diagnostic-Review---Banking-and-Non-Banking-Credit-Institutions---V-II.pdf) retrieved 2026-07-04 6. T3 [https://clubofmozambique.com/news/mozambique-central-bank-fines-nine-financial-institutions-for-violating-regulations-275645/](https://clubofmozambique.com/news/mozambique-central-bank-fines-nine-financial-institutions-for-violating-regulations-275645/) retrieved 2026-07-04 ### W2 Stablecoins & Digital Money limited signal Probable confirmed 2026-07-04 Aviso No. 4/GBM/2026 establishes new limits on outbound payments abroad made via bank cards, revoking Aviso No. 9/GBM/2025 of 9 December 2025. The specific new limit value has not been resolved from indexed source text this cycle. Standing sub-brief · as of 4 July 2026 181 words · last cycle 2026-10-18 #### Stablecoins & Digital Money Mozambique has not issued a comprehensive stablecoin or crypto-asset regulatory framework. Cryptocurrency use remains legal but substantively unregulated: as of 2025, crypto trading operates in a regulatory grey area, with Banco de Moçambique's engagement limited to the AML-oriented monitoring role performed by GIFiM rather than any product-level authorisation or prudential framework for crypto-assets or stablecoins. No central bank digital currency pilot was identified in the sources reviewed this cycle. The only formal touchpoint between Mozambique's regulatory perimeter and digital-asset activity is the VASP registration regime addressed under W1a (Aviso No. 4/GBM/2023), which registers virtual-asset service providers without constituting a substantive stablecoin or crypto-asset law. #### Outlook With no stablecoin law and no CBDC exploration currently on record, this module's trajectory is properly read as stable rather than escalating: Mozambique's digital-money activity is being channelled through the VASP registration gateway and general AML monitoring rather than through dedicated product regulation. Any shift toward substantive crypto-asset or stablecoin rulemaking, or toward CBDC exploration, would represent a material change from the current baseline and should be watched for in subsequent cycles. Periodic update · new data 2026-10-18 #### Stablecoins & Digital Money Lei n.º 15/2026, Mozambique's National Payment System law, grants legal recognition to distributed-ledger technologies, including blockchain, for opening, maintaining and settling securities-account-related operations. This is a payments-infrastructure provision embedded within a general supervisory law rather than a dedicated stablecoin or digital-money statute: the recognition applies to DLT as a settlement mechanism for securities-account operations, not to any specific fiat-referenced token, central bank digital currency, or stablecoin issuance and redemption framework. Alongside the DLT recognition, the same law empowers Banco de Moçambique to establish regulatory sandboxes for financial innovation and inclusion. This sandbox power gives the central bank a formal mechanism through which novel payment and settlement technologies, potentially including digital-money products, could be trialled under supervised conditions, though no specific sandbox cohort or product has been identified in the evidence available this period. No evidence this period points to a stablecoin-specific issuance, reserve, or redemption regime, nor to any central bank digital currency development, in Mozambique. The DLT recognition and sandbox powers under Lei n.º 15/2026 represent the closest adjacent developments, both general payments-infrastructure provisions rather than digital-money-specific regulation. #### Outlook The item to watch is whether Banco de Moçambique uses its new regulatory sandbox power to trial any stablecoin, digital-money or DLT-settlement product, and whether the general DLT recognition for securities-account operations is extended or clarified through subsequent regulation specific to digital-money instruments. Given the law's recency, in force since August 2026, concrete applications of either the DLT recognition or the sandbox power are most likely to surface in the period ahead. **1 earlier distinct update(s)** Periodic update · new data 2026-09-08 #### Stablecoins & Digital Money Aviso No. 4/GBM/2026 establishes new limits on outbound payments abroad made via bank cards, revoking Aviso No. 9/GBM/2025 of 9 December 2025; the specific new limit value was not resolved from indexed source text this cycle. #### Outlook This is a dashboard-tier item pending resolution of the specific new limit value; the direction of Mozambique's outbound card-payment posture cannot yet be assessed from indexed text. **Sources and findings (5)** 1. T3 [https://freemanlaw.com/cryptocurrency/mozambique/](https://freemanlaw.com/cryptocurrency/mozambique/) retrieved 2026-07-04 2. T4 [https://incfine.com/en/obtaining-a-crypto-license-in-mozambique/](https://incfine.com/en/obtaining-a-crypto-license-in-mozambique/) retrieved 2026-07-04 3. T4 [https://cryptovanguards.com/best-crypto-exchanges-in-mozambique/](https://cryptovanguards.com/best-crypto-exchanges-in-mozambique/) retrieved 2026-07-04 4. T4 [https://www.transfi.com/blog/stablecoin-payments-in-mozambique-unlocking-crypto-remittances-and-local-payments](https://www.transfi.com/blog/stablecoin-payments-in-mozambique-unlocking-crypto-remittances-and-local-payments) retrieved 2026-07-04 5. T4 [https://blog.mexc.com/wiki/is-crypto-legal-in-mozambique/](https://blog.mexc.com/wiki/is-crypto-legal-in-mozambique/) retrieved 2026-07-04 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-04 BM launched the Mozambique Instant Payment System (SPIM/METIX) under Notice 1/GBM/2026, operated by the Interbank Society of Mozambique (SIMO), running 24/7 with per-transaction daily limits of 200,000 MZN for individuals and 500,000 MZN for legal entities; interbank individual transactions via SPIM are fee-exempt. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/mozambique/) Standing sub-brief · as of 4 July 2026 200 words · last cycle 2026-09-28 #### Operational Resilience & Critical Infrastructure Mozambique's Parliament unanimously approved a Cybersecurity Law in April 2026, and the government has since begun mapping Critical Information Infrastructure and conducting business-impact assessments with World Bank support. A pending legal framework is expected to designate Critical Information Infrastructure operators and set proportionate obligations for them, though no date for that framework had been set as of this cycle's sources. This reform is explicitly precedent-driven: in 2018, a vendor-licensing dispute triggered a nationwide blackout of the SIMORede payment system, leaving hospitals, schools and businesses unable to process electronic payments. That episode remains the reference case cited for the current resilience push, illustrating the concrete cost of third-party and vendor-dependency risk in Mozambique's payments infrastructure. #### Outlook This module is escalating: the Cybersecurity Law and CII-mapping exercise represent Mozambique's first systematic move toward operational-resilience regulation for payments and other critical systems, following years in which the 2018 SIMORede blackout stood as the primary cautionary precedent without a corresponding statutory framework. The key forward marker is the still-undated legal framework that will designate CII operators and their obligations; until that framework is published, the practical scope of the new law for payment-system operators specifically remains to be defined. Periodic update · new data 2026-09-29 #### Operational Resilience & Critical Infrastructure Law 15/2026 introduces a specific user-protection provision with direct operational-resilience implications: it prohibits payment-system operators from charging transaction fees where the transaction fails due to technical failure. This shifts the cost of technical failure from the user to the operator, creating a direct financial incentive for operators to invest in resilience and failure-reduction measures rather than treating failed-transaction fees as a neutral or acceptable cost passed through to customers. This provision sits within the broader Law 15/2026 overhaul of Mozambique's payment-systems legal framework, discussed in more detail under the licensing and market-access module, but its operational-resilience content is distinct enough to warrant separate note: it is a conduct-and-resilience rule embedded in a market-access-and-licensing instrument, tightening the practical bar operators must clear on system reliability. No further detail is available this cycle on enforcement mechanisms for this specific provision, such as how a technical failure is defined or adjudicated, or what penalty attaches to non-compliance. #### Outlook The practical operation of the technical-failure fee prohibition is the item to watch: whether it generates observable dispute activity, enforcement guidance, or operator-level resilience investment as the 180-day adaptation window under Law 15/2026 closes. Any Banco de Moçambique guidance further defining what constitutes a technical failure for purposes of this provision would be a material clarifying development. **2 earlier distinct update(s)** Periodic update · new data 2026-09-14 #### Operational Resilience & Critical Infrastructure Banco de Moçambique established the Mozambique Instant Payment System, branded SPIM or METIX, under Notice 1/GBM/2026, a Tier-1 primary regulatory notice corroborated by Tier-2 and Tier-3 press reporting. The system is operated and managed by SIMO, the Interbank Society of Mozambique, and runs on a 24-hours-a-day, seven-days-a-week basis. Daily transaction limits are set at 200,000 MZN for individual users and 500,000 MZN for legal entities. Interbank individual transactions on the system are fee-exempt, a detail corroborated by Tier-3 local press alongside the Tier-1 notice itself. The infrastructure's defining feature is its integration scope: SIMO's instant-payment rail brings together traditional bank accounts and the country's dominant mobile-money wallets, M-Pesa, e-Mola and mKesh, onto common instant-settlement infrastructure. In a market where mobile-money penetration has historically outpaced formal bank-account access, this bank-to-wallet interoperability is the most structurally significant element of the launch, extending real-time settlement finality across rails that previously operated on largely separate technical and commercial footings. The launch is confirmed with high confidence across a Tier-1 primary source and Tier-2 corroboration on the operating-entity and integration details. This infrastructure development runs concurrently with, and is plausibly coordinated with, the Law 15/2026 market-access reset addressed under Licensing, Authorisation & Market Access above; together they represent Banco de Moçambique's broader modernisation of the national payment-systems architecture this cycle, rather than two isolated initiatives. #### Outlook The marker to watch is transaction-volume growth on SPIM/METIX now that bank and mobile-money wallets sit on shared instant-settlement rails with fee-free interbank individual transfers; sustained adoption would be a significant structural access-expansion signal. Any adjustment to the daily transaction limits, or extension of the system to additional wallet providers or cross-border corridors, would also be material to this module in a subsequent cycle. Periodic update · new data 2026-08-25 #### Operational Resilience & Critical Infrastructure The SPIM Regulation, approved under Notice 1/GBM/2026 and in force since 2 March 2026, mandates that the instant-payment mechanism operate 24 hours a day continuously, including weekends, public holidays and official bridge days. This is a high-confidence, T1 primary-source finding establishing an always-on operational-resilience baseline for Mozambique's core retail payment infrastructure. Banking-sector guidance anticipates further resilience-adjacent detail: deadlines for availability of funds (same-day, D, and next-day, D+1), finality and irrevocability of payment instructions once cleared, communicated-reason return procedures for failed or rejected transactions, and mandatory contingency mechanisms for network disruption. These provisions, sourced from T3 banking-guidance commentary rather than the primary Notice text itself, describe the operational contract that both bank and non-bank participants must meet to remain connected to the METIX rail. #### Outlook Watch for confirmation of the specific contingency-mechanism technical standards referenced in banking-sector guidance, and for any reported network-disruption incidents that would test the 24/7 continuous-operation mandate in practice. **Sources and findings (6)** 1. T2 [https://blogs.worldbank.org/en/nasikiliza/protecting-mozambique-digital-future-cyber-resilience-for-jobs-trust-and-growth-](https://blogs.worldbank.org/en/nasikiliza/protecting-mozambique-digital-future-cyber-resilience-for-jobs-trust-and-growth-) Applies beyond this jurisdiction (World Bank) retrieved 2026-07-04 2. T2 [https://blogs.worldbank.org/en/nasikiliza/protecting-mozambique-digital-future-cyber-resilience-for-jobs-trust-and-growth-](https://blogs.worldbank.org/en/nasikiliza/protecting-mozambique-digital-future-cyber-resilience-for-jobs-trust-and-growth-) Applies beyond this jurisdiction (World Bank) retrieved 2026-07-04 3. T2 [https://blogs.worldbank.org/en/nasikiliza/protecting-mozambique-digital-future-cyber-resilience-for-jobs-trust-and-growth-](https://blogs.worldbank.org/en/nasikiliza/protecting-mozambique-digital-future-cyber-resilience-for-jobs-trust-and-growth-) Applies beyond this jurisdiction (World Bank) retrieved 2026-07-04 4. T3 [https://www.trade.gov/country-commercial-guides/mozambique-digital-economy](https://www.trade.gov/country-commercial-guides/mozambique-digital-economy) Applies beyond this jurisdiction (World Bank) retrieved 2026-07-04 5. T3 [https://www.mozambiqueexpert.com/en/mozambique-banking-sector/](https://www.mozambiqueexpert.com/en/mozambique-banking-sector/) Applies beyond this jurisdiction (World Bank) retrieved 2026-07-04 6. T3 [https://furtherafrica.com/2026/03/24/risk-management-resilience-mozambique/](https://furtherafrica.com/2026/03/24/risk-management-resilience-mozambique/) Applies beyond this jurisdiction (World Bank) retrieved 2026-07-04 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-04 The national card/payment switch is operated by SIMO (Sociedade Interbancária de Moçambique) in partnership with US firm Euronet, which has replaced the legacy SIMOrede platform since 2018/2023 to bring ATM/POS infrastructure into line with international contactless standards. Visa dominates card acceptance (over 90% share) while the Euronet migration caused recurring Mastercard acceptance disruption. Mozambique also participates in the SADC-RTGS/SIRESS regional card-scheme cooperation network. Standing sub-brief · as of 11 August 2026 215 words · last cycle 2026-08-05 #### Scheme & Network Compliance SIMO, operated together with Euronet, runs Mozambique's national card and payment switch, and has been migrating away from the legacy SIMOrede platform since 2018/2023. Visa holds over 90% of card acceptance share in the country, and the ongoing migration has caused recurring Mastercard acceptance disruption - a durable friction point in the card-scheme layer even as Visa's position remains dominant. The more consequential scheme-level development this cycle is Notice No. 1/GBM/2026, which establishes the Mozambique Instant Payment System (SPIM) and, critically, makes participation mandatory not only for credit institutions but for electronic money institutions and Banco de Moçambique-authorised digital wallet operators. This is a direct extension of scheme participation obligations to non-bank e-money issuers, tracked on the standing "Scheme Rule Changes" tracker as escalating alongside the SIMO/Euronet migration itself, and on the "Instant Payments" tracker as newly established. #### Outlook Scheme compliance in Mozambique is running on two simultaneous tracks: legacy card-scheme migration friction that continues to generate intermittent Mastercard acceptance problems despite Visa's dominant share, and a newly mandatory instant-payment participation regime that pulls EMIs and wallet operators into scheme-level obligations for the first time. The near-term question is whether SIMO/Euronet migration disruption resolves before EMI participation in SPIM meaningfully scales, since both dynamics touch the same merchant-acceptance and consumer-experience layer. Periodic update · new data 2026-08-11 #### Scheme & Network Compliance Banco de Mocambique has imposed an aggregate outbound card-payment limit of 6,000,000 MZN per year per account holder, approximately USD 94,000, for cross-border card payments. The annual ceiling is structured with sub-limits of approximately 500,000 MZN per month, 125,000 MZN per week, and 16,400 MZN per day, with higher limits authorisable on a case-by-case basis up to the annual cap. This is a Tier 3-sourced, high-confidence dated development applying specifically to bank-issued cards; the record does not evidence an equivalent limit on non-bank-issued payment instruments this cycle. #### Outlook Watch for whether Banco de Mocambique publishes a formal notice corroborating this limit at Tier 1, and for any extension of an equivalent control to non-bank card or account-based cross-border payment instruments. **Sources and findings (5)** 1. T3 [https://www.trade.gov/country-commercial-guides/mozambique-digital-economy](https://www.trade.gov/country-commercial-guides/mozambique-digital-economy) retrieved 2026-07-04 2. T3 [https://www.trade.gov/country-commercial-guides/mozambique-trade-financing](https://www.trade.gov/country-commercial-guides/mozambique-trade-financing) retrieved 2026-07-04 3. T4 [https://www.oficinatic.com/en/novas/mastercard-status-mocambique/](https://www.oficinatic.com/en/novas/mastercard-status-mocambique/) retrieved 2026-07-04 4. T1 [https://www.bancomoc.mz/en/areas-of-expertise/payment-systems/cooperation-with-the-market/](https://www.bancomoc.mz/en/areas-of-expertise/payment-systems/cooperation-with-the-market/) retrieved 2026-07-04 5. T3 [https://clubofmozambique.com/news/mozambique-banks-unveil-instant-payment-system/](https://clubofmozambique.com/news/mozambique-banks-unveil-instant-payment-system/) retrieved 2026-07-04 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-04 Bank of Mozambique halved and made permanent the annual foreign-card-payment ceiling (Aviso 4/GBM/2026, in force 28 July 2026), replacing a sunsetting 2025 measure. Standing sub-brief · as of 4 July 2026 241 words · last cycle 2026-10-18 #### Payment Corridor Dynamics Mozambique's primary formal cross-border settlement channel is SADC-RTGS, the ZAR-denominated, SARB-operated regional real-time gross settlement system that Mozambique joined in October 2016. That membership reduces the country's reliance on traditional bilateral correspondent banking for regional flows (see also W12). Domestically, the Mozambique Instant Payment System - branded METIX - launched on 16 March 2026 in Matola as a 24/7/365 retail instant-payment rail, with daily transaction limits of 200,000 meticais for individuals and 500,000 meticais for legal entities. The launch-date and limit specifics rest on a single T3 news anchor, though the underlying regulatory basis, Notice 1/GBM/2026, is separately confirmed at T1. SPIM/METIX is tracked on the standing "Instant Payments" and "Major Product Launches" trackers, both marked established this cycle. Set against that domestic launch, the formal South Africa-Mozambique remittance corridor - one of the four largest formal SADC remittance destination markets - has been contracting: formal remittance volumes are down 36% since a 2022 peak, with flows shifting toward informal channels. #### Outlook The corridor picture this cycle is bifurcated: domestic instant-payment infrastructure is opening up new formal rails just as the largest formal inbound remittance corridor is contracting toward informality. Whether SPIM/METIX's mobile-wallet reach (via mandatory EMI participation, see W4) can be extended to capture some of the remittance volume currently migrating to informal channels is an open question not addressed in current sources, but it is the natural point of convergence between this module's two active dynamics. Periodic update · new data 2026-10-18 #### Payment Corridor Dynamics Banco de Moçambique's Aviso n.º 7/GBM/2026, de 1 de Outubro extends the exceptional foreign-exchange export-earnings conversion regime by a further six months from 9 October 2026. Under this regime, 50 percent of foreign-currency receipts from exports and related transactions must be converted, a measure the central bank has now extended rather than allowed to lapse. The notice itself gives no detailed justification beyond stating the need to extend the period, which leaves the regime's underlying rationale somewhat opaque from the public notice alone. Separately, the central bank's governor has addressed claims of a structural foreign-currency shortage in Mozambique by pointing to FX purchase volume data: up to August 2026, the banking system purchased USD 5,730 million in foreign currency from exporters and other economic agents, an increase of USD 724 million over the same period the prior year. This figure is presented as grounds for caution about shortage narratives, suggesting the central bank's own data shows FX inflows through the banking system growing rather than contracting, even as the exceptional conversion regime continues to be extended. The coexistence of rising measured FX purchase volumes with a continued exceptional conversion requirement is a notable tension in the corridor-dynamics picture for Mozambique: a measure introduced to address foreign-currency scarcity continues even as the central bank's own cited data points away from scarcity as the dominant narrative. No information was available this period on how the conversion regime is applied operationally across different corridor routes or counterparty types, nor on any sector-specific carve-outs from the 50 percent conversion requirement. #### Outlook The six-month extension running from 9 October 2026 sets the next natural decision point for the regime in the first half of 2027. Given the governor's public emphasis on rising FX purchase volumes as a reason for caution about shortage claims, there is a plausible basis to watch for either a further extension framed differently, or the beginning of a wind-down of the exceptional conversion requirement, at that review point. **3 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Payment Corridor Dynamics The cross-border card corridor for Mozambican consumers tightened materially this cycle. Aviso n.º 4/GBM/2026 halved the annual ceiling on foreign payments made using Mozambican-issued cards, reducing the limit from 6,000,000 to 3,000,000 meticais per calendar year. The notice took effect on 28 July 2026 and formally revoked the prior Aviso 9/GBM/2025, which had set the now-superseded 6,000,000-meticai ceiling. Notably, the new notice carries no sunset clause, which distinguishes it from a temporary foreign-exchange-management measure and signals that the halved ceiling is intended to function as a standing feature of Mozambique's outbound card-payment corridor rather than a response to a transient pressure. This tightening sits in a market where the balance of payment flows is increasingly mediated by mobile-money rails domestically, even as card-based payment capacity for cross-border, foreign-currency-denominated spending is being constrained. The corridor dynamic this cycle is therefore asymmetric: domestic non-bank payment access is widening through new PSP licensing activity, while the specific corridor for outbound card-based foreign spending is narrowing under central-bank direction. For cardholders and card-issuing institutions, the practical effect is a lower annual cap on legitimate cross-border card usage, which in turn raises the relative importance of alternative cross-border payment channels for any Mozambican consumer or business whose foreign-currency needs would otherwise have exceeded the new, lower ceiling. No Bank of Mozambique primary notice text for Aviso n.º 4/GBM/2026 has been directly retrieved; the finding rests on a single corroborating secondary report. The absence of a located primary text means the precise scope of the ceiling, whether it applies per card, per cardholder, or per account, and any exceptions or carve-outs, have not been independently confirmed. #### Outlook With no sunset clause attached to the halved ceiling, the corridor constraint should be treated as the new baseline for cross-border card payments out of Mozambique going forward, rather than as a temporary restriction likely to revert. Future cycles should prioritise retrieving the Bank of Mozambique's primary text of Aviso n.º 4/GBM/2026 to confirm the precise scope and any exceptions to the ceiling, and should monitor whether the tightened card corridor drives measurable growth in alternative cross-border payment channels. Periodic update · new data 2026-09-05 #### Payment Corridor Dynamics Banco de Moçambique's Notice 1/GB/2026 establishes the Mozambique Instant Payment System, providing 24/7 availability and operated by SIMO, the national interbank settlement operator. The system has been characterised as adjusted to international best practices for instant-payment infrastructure, marking a structural upgrade to Mozambique's domestic payment corridor rather than an incremental adjustment to an existing rail. The regulation sets daily transfer caps of MZN200,000 for individual transfers and MZN500,000 for legal entities, a limit structure that will directly shape the volume and profile of transactions that can move through this new corridor. These caps position the system for high-frequency retail and small-business use rather than for large-value corporate settlement, which will presumably continue to rely on existing correspondent and bank-to-bank channels outside the instant-payment rail. This launch should be read as establishing the foundational domestic corridor infrastructure against which other payment developments in this market, including bank-to-mobile-money interoperability, will increasingly operate. The 24/7 availability characteristic is itself a significant corridor-dynamics feature, since it removes settlement-window constraints that previously limited when domestic transfers could clear. #### Outlook The key question for the coming cycle is real-world uptake: transaction volumes migrating onto the new instant-payment rail, and whether the MZN200,000 and MZN500,000 daily caps prove to be binding constraints in practice for individual and business users respectively. Any adjustment to these caps, or extension of the system's reach to additional participant banks, would be the next material development to watch. Periodic update · new data 2026-08-25 #### Payment Corridor Dynamics Mozambique's instant-payment corridor now operates under an explicit tiered transaction-limit architecture. Financial institutions may set daily maximum SPIM limits of 200,000 MZN (approximately US$3,129) for individuals and 500,000 MZN (approximately US$7,824) for legal entities per account. All individual-ordered interbank SPIM transactions are exempt from fees or commissions, a high-confidence, T1 primary-source finding drawn from Banco de Moçambique's own determination. IME wallets carry a parallel but distinct tiered-limit structure: up to 200,000 MZN for Level 1 wallets, 500,000 MZN for Level 2, and 3,000,000 MZN for Level 3 wallets. This tiering functions as a de facto risk-graduated safeguard mechanism rather than a segregation or insurance-based safeguarding regime, differentiating wallet users by verification tier rather than by institution type. Together, the individual/entity limits and the IME wallet tiers define the practical capacity ceiling of Mozambique's domestic instant-payment corridor for both bank-account holders and mobile-wallet users. #### Outlook Watch for whether these transaction-limit tiers are revised as SPIM usage scales, and for any divergence in limit-setting practice between individual banks and IME operators within the ceilings the Regulation permits. **Sources and findings (5)** 1. T1 [https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/cross-border-payments-conference/documents/paper-sa-sadc.pdf](https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/cross-border-payments-conference/documents/paper-sa-sadc.pdf) retrieved 2026-07-04 2. T1 [https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGS](https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGS) retrieved 2026-07-04 3. T1 [https://www.bancomoc.mz/en/media/highlights/notice-no-1-gbm-2026-establishes-the-mozambique-instant-payment-system-and-approves-its-regulation/](https://www.bancomoc.mz/en/media/highlights/notice-no-1-gbm-2026-establishes-the-mozambique-instant-payment-system-and-approves-its-regulation/) retrieved 2026-09-08 4. T3 [https://aimnews.org/2026/03/16/banco-central-lanca-sistema-de-pagamentos-instantaneos/](https://aimnews.org/2026/03/16/banco-central-lanca-sistema-de-pagamentos-instantaneos/) retrieved 2026-07-04 5. T2 [https://www.boz.zm/payment-systems/regional-payment-systems](https://www.boz.zm/payment-systems/regional-payment-systems) retrieved 2026-07-04 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-04 Mozambique's financial sector is bank-dominated by three institutions (Millennium BIM, BCI, Standard Bank) controlling over 70% of assets, alongside 15 commercial banks and 12 microbanks in total; but usage is dominated by mobile money, with three MNO-affiliated IMEs (M-Pesa, e-Mola, M-Kesh) covering far more accounts than traditional banks. The standalone fintech/startup ecosystem remains nascent and largely telecom/bank-linked rather than venture-driven. Standing sub-brief · as of 4 July 2026 129 words · last cycle 2026-09-28 #### Industry Structure & Commercial Dynamics Mozambique's financial sector is bank-asset-concentrated but mobile-money-usage-dominated. Three banks - Millennium BIM, BCI and Standard Bank - hold more than 70% of banking-sector assets, while mobile-wallet accounts (24.6 million) substantially outnumber bank accounts (6.6 million). This is a single-T3-sourced figure this cycle, though partially corroborated by additional T3 reporting on bank-asset concentration specifically. #### Outlook The structural picture is one of balance-sheet concentration sitting with a small number of banks while transactional reach and day-to-day usage sit overwhelmingly with mobile-money wallets operated as MNO-affiliated IMEs. As SPIM/METIX extends mandatory instant-payment participation to those same wallet operators (W4/W5), this usage-dominant but asset-light non-bank layer is being drawn further into core payments infrastructure, a dynamic worth monitoring for its effect on industry concentration metrics in future cycles. Periodic update · new data 2026-09-29 #### Industry Structure & Commercial Dynamics Mozambique's payments industry structure has shifted decisively toward non-bank agent-network distribution. Non-banking agent networks surged 1,158.5 percent between 2015 and 2023, growing to over 224,704 agents, a scale that now surpasses formal bank branch coverage across the country. This is a structural, not episodic, shift: the agent-based distribution model, closely associated with mobile-money services, is now the dominant channel through which Mozambicans access financial services, ahead of the traditional bank-branch network that historically defined formal financial access. This agent-network scale has direct implications for how Law 15/2026's registration requirements will play out in practice, since a very large share of Mozambique's payment-system touchpoints now run through non-bank agent channels rather than bank branches, reinforcing the importance of the bank-PSP versus non-bank distinction carried elsewhere in this brief. Separately, Banco de Moçambique is reported to be reviewing rules governing the use of artificial intelligence, with the review anticipated during 2026. This signals the regulator's attention is extending beyond the core payment-systems legal overhaul toward newer technology-governance questions, though no further substantive detail on the scope or timeline of that AI-rules review is available this cycle. #### Outlook The trajectory of non-bank agent-network growth, and whether it continues to outpace formal bank-branch expansion, is the key structural indicator to track for Mozambique's payments market. Banco de Moçambique's anticipated 2026 review of AI-use rules is a distinct item to watch, particularly for any implications it may carry for the technology used to manage the now-dominant agent-network distribution channel. **1 earlier distinct update(s)** Periodic update · new data 2026-09-05 #### Industry Structure & Commercial Dynamics M-Pesa, operated by Vodacom, and Absa Bank Mozambique signed a memorandum of understanding at FACIM 2026 linking the Paga Fácil merchant service to Absa bank accounts. This is a discrete commercial partnership-restructuring event between a leading mobile-money operator and a commercial bank, announced without publicly disclosed financial terms. Structurally, it represents a further step in the deepening interoperability between bank rails and mobile-money rails in the Mozambican market, a pattern that has been building gradually as mobile-money operators and banks each seek to extend the reach of their respective payment services into the other's customer base. This partnership sits within a market structure where mobile-money and bank-operated payment services have historically operated as largely separate rails, with mobile-money serving the unbanked and underbanked segment particularly effectively while banks retained corporate and higher-value retail relationships. An MOU of this kind, linking a merchant-payment service to a bank account structure, is consistent with a broader industry trend toward converging these previously distinct rails, though the commercial and technical details of how the integration will function have not yet been disclosed. #### Outlook The development to watch is whether this memorandum of understanding progresses to an operational, technically integrated product, and on what timeline. No financial terms were disclosed, so the commercial scale of the partnership remains unknown; confirmation of a live, integrated product linking Paga Fácil and Absa accounts would be the clearest signal of how far bank/mobile-money convergence has progressed in this market. **Sources and findings (5)** 1. T3 [https://www.mozambiqueexpert.com/en/mozambique-banking-sector/](https://www.mozambiqueexpert.com/en/mozambique-banking-sector/) retrieved 2026-07-04 2. T3 [https://clubofmozambique.com/news/mozambique-banks-unveil-instant-payment-system/](https://clubofmozambique.com/news/mozambique-banks-unveil-instant-payment-system/) retrieved 2026-07-04 3. T3 [https://www.mozambiqueexpert.com/en/mozambiqu-mobile-money-operators-mmo/](https://www.mozambiqueexpert.com/en/mozambiqu-mobile-money-operators-mmo/) retrieved 2026-07-04 4. T3 [https://thefintechtimes.com/fintech-in-the-east-african-nation-of-mozambique-in-2026/](https://thefintechtimes.com/fintech-in-the-east-african-nation-of-mozambique-in-2026/) retrieved 2026-07-04 5. T3 [https://tracxn.com/d/explore/fintech-startups-in-mozambique/yCpaKPFTlkZqAiiUSM-AykzOdW_XbrZPYNwVJfO4-8A#top-companies](https://tracxn.com/d/explore/fintech-startups-in-mozambique/yCpaKPFTlkZqAiiUSM-AykzOdW_XbrZPYNwVJfO4-8A#top-companies) retrieved 2026-07-04 ### W7 Legal & Litigation Confirmed confirmed 2026-07-04 The dominant financial-sector litigation touching Mozambique is the 'tuna bonds' hidden-debt scandal: state-guaranteed loans from Credit Suisse/VTB were later ruled illegal, leading to a 2024 English High Court judgment substantially in Mozambique's favour and a US$3.1bn award against Privinvest, alongside Credit Suisse's own ~$500m global regulatory settlement and the 2024 US conviction of former finance minister Manuel Chang. Domestically, BdM's administrative-sanctions regime is active, with recurring fines against banks and IMEs for prudential, AML/CFT, forex and consumer-protection breaches. Standing sub-brief · as of 4 July 2026 262 words · last cycle 2026-07-04 #### Legal & Litigation The dominant legal and litigation development for Mozambique's payments and financial sector is the "tuna bonds" hidden-debt scandal, which reached decisive milestones in this cycle's reporting window. A 2024 English High Court judgment substantially favoured Mozambique, producing a US$3.1 billion award against Privinvest. Credit Suisse and its subsidiary CSSEL resolved the matter for US$547 million, part of a coordinated global resolution totalling roughly US$500 million in aggregate fines, and former Mozambican finance minister Manuel Chang was convicted in the United States in 2024. This is tracked on the standing "Payments Litigation" tracker as escalating, and represents the highest-impact single item in this cycle's Mozambique findings (rated CRITICAL). Separately, and on a more routine cadence, Banco de Moçambique operates an active sanctions regime against credit institutions and financial companies for prudential, AML/CFT, forex and consumer-protection breaches. Nine institutions were fined between December 2023 and December 2024 under Law 20/2020 and Law 11/2022, and further fines were imposed in late 2025 against FNB Mozambique, Banco Letshego, BIM and MyBucks. #### Outlook The tuna-bonds litigation cycle appears to be reaching a point of resolution on its major fronts - judgment, global settlement and criminal conviction - which should, over time, reduce this specific item's ongoing salience even as its reputational and market-confidence effects persist. The domestic sanctions cadence, by contrast, shows no sign of slowing and should be read as a standing feature of Mozambique's supervisory environment rather than an episodic one. Note that the tuna-bonds affair's bribery, embezzlement and sovereign-debt fraud dimensions extend beyond WPM's payments-market scope and are flagged to FIM. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T4 [https://en.wikipedia.org/wiki/Tuna_bonds](https://en.wikipedia.org/wiki/Tuna_bonds) retrieved 2026-07-04 2. T3 [https://www.seafoodsource.com/news/supply-trade/mozambique-wins-usd-3-1-billion-in-lawsuit-over-tuna-bond-scandal](https://www.seafoodsource.com/news/supply-trade/mozambique-wins-usd-3-1-billion-in-lawsuit-over-tuna-bond-scandal) retrieved 2026-07-04 3. T1 [https://www.justice.gov/usao-edny/pr/credit-suisse-resolves-fraudulent-mozambique-loan-case-547-million-coordinated-global](https://www.justice.gov/usao-edny/pr/credit-suisse-resolves-fraudulent-mozambique-loan-case-547-million-coordinated-global) retrieved 2026-07-04 4. T1 [https://www.bancomoc.mz/media/kahpjmb1/fines-imposed-on-credit-institutions.pdf](https://www.bancomoc.mz/media/kahpjmb1/fines-imposed-on-credit-institutions.pdf) retrieved 2026-07-04 5. T3 [https://clubofmozambique.com/news/bank-of-mozambique-sanctions-commercial-banks-and-managers-aim-report-251316/](https://clubofmozambique.com/news/bank-of-mozambique-sanctions-commercial-banks-and-managers-aim-report-251316/) retrieved 2026-07-04 6. T3 [https://clubofmozambique.com/news/mozambique-central-bank-fines-nine-financial-institutions-for-violating-regulations-275645/](https://clubofmozambique.com/news/mozambique-central-bank-fines-nine-financial-institutions-for-violating-regulations-275645/) retrieved 2026-07-04 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04 Merchant acquiring in Mozambique runs through the SIMO/Euronet national switch connecting banks and EMIs to POS/ATM infrastructure. Physical card-acceptance infrastructure has contracted slightly even as digital-wallet usage surges: POS terminals fell from 35,470 to 33,191 and ATMs from 1,413 to 1,399 in the year to November, while the ongoing Mastercard/Visa migration has created intermittent card-acceptance risk for merchants and cardholders. Standing sub-brief · as of 4 July 2026 135 words · last cycle 2026-07-04 #### Merchant Acquiring & Risk Mozambique's physical card-acceptance infrastructure contracted slightly over the year to November: point-of-sale terminals fell from 35,470 to 33,191, and ATMs fell from 1,413 to 1,399, even as digital-wallet usage continued to surge. This single-T3-sourced figure sits alongside the SIMO/Euronet migration-related Mastercard acceptance disruption documented under W4, suggesting that acquiring-side friction in Mozambique currently has two distinct sources: a modest contraction in physical terminal/ATM footprint, and scheme-migration-related acceptance interruption. #### Outlook The contraction in physical acceptance infrastructure, set against surging digital-wallet usage and the new SPIM/METIX rail, is consistent with a broader shift of retail payment activity away from card-present physical acceptance and toward account-based and wallet-based instant payments. Whether this reflects a deliberate acquirer rationalisation of underused terminals or a funding/investment constraint on physical acceptance infrastructure is not addressed in current sources. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://clubofmozambique.com/news/mozambique-banks-unveil-instant-payment-system/](https://clubofmozambique.com/news/mozambique-banks-unveil-instant-payment-system/) retrieved 2026-07-04 2. T3 [https://www.trade.gov/country-commercial-guides/mozambique-trade-financing](https://www.trade.gov/country-commercial-guides/mozambique-trade-financing) retrieved 2026-07-04 3. T3 [https://www.mozambiqueexpert.com/en/mozambiqu-mobile-money-operators-mmo/](https://www.mozambiqueexpert.com/en/mozambiqu-mobile-money-operators-mmo/) retrieved 2026-07-04 4. T4 [https://www.oficinatic.com/en/novas/mastercard-status-mocambique/](https://www.oficinatic.com/en/novas/mastercard-status-mocambique/) retrieved 2026-07-04 ### W9 Product Innovation & Market Development Confirmed confirmed 2026-07-04 Mozambique's Instant Payment System, METIX, moved from regulatory approval to live operation this cycle. Established by Notice No. 1/GBM/2026 (25 February 2026), the 24/7/365 electronic retail rail was formally rolled out by the Governor in Matola around mid-August 2026 and is now accessible via internet banking, mobile apps and USSD to any account-holder at an institution connected to the SIMO network, with fee-free individual interbank transfers. Horizon · 2027 (±year) National Financial Inclusion Strategy (ENIF) first phase concludes_in_force · TT3_ Horizon · 2027 (±year) National Financial Inclusion Strategy (ENIF) first phase concludes_in_force · TT3_ Standing sub-brief · as of 11 August 2026 170 words · last cycle 2026-09-08 #### Product Innovation & Market Development Banco de Moçambique launched the seventh edition of its Regulatory Sandbox this cycle, framed within the National Financial Inclusion Strategy 2025-2031 (ENIF) and inviting fintechs and aggregators to work on inclusive digitalisation, consumer protection and green finance themes. The sandbox was first established in 2018 and has now reached its seventh iteration, indicating a sustained, institutionalised innovation channel rather than a one-off initiative. The other major product-innovation development is the Mozambique Instant Payment System itself, which Notice 1/GBM/2026 explicitly frames - beyond its infrastructure function addressed under W4/W5 - as a vehicle for promoting digitalisation, financial inclusion and innovation within the financial system. #### Outlook With the sandbox's seventh edition running concurrently with SPIM's 2026 launch, and both explicitly tied to the ENIF 2025-2031 strategy, Mozambique's product-innovation posture this cycle is escalating and institutionally coordinated. ENIF's first phase is expected to conclude around 2027, which is the natural horizon marker against which to assess whether sandbox output and SPIM adoption have converted into measurable financial-inclusion gains. Periodic update · new data 2026-08-25 #### Product Innovation & Market Development Two early-stage regulatory-innovation signals surfaced this cycle. Banco de Moçambique is analysing rules that would require banks to incorporate AI technologies in a regulated manner, addressing risk, opportunity and digital-supervision dimensions; no rule has been finalised as of 2026, and this remains an assessed-confidence, T3-sourced finding at the consultation-analysis stage. Separately, the National Financial Inclusion Strategy 2025-2031 foresees future implementation of consumer data-protection and cybersecurity regulation that would oblige banks to review privacy policies and strengthen digital infrastructure, with an anticipated horizon extending toward 2031. Both developments are forward-looking policy signals rather than binding rules, and both would apply primarily to bank/PSP-type institutions per current sourcing rather than IMEs specifically. #### Outlook Watch for whether Banco de Moçambique's AI-in-finance analysis progresses to a formal consultation stage, and for the pace at which the National Financial Inclusion Strategy's data-protection and cybersecurity commitments translate into drafted regulation ahead of the 2031 horizon. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### Product Innovation & Market Development Mozambique's National Financial Inclusion Strategy 2025-2031 anchors this cycle's product-innovation and market-development picture. Launched in August 2025 and reported at Tier 3 confidence via the MENA Fintech Organisation, the strategy's first phase, running from 2025 to 2027, prioritises three areas: expanding access to financial services, strengthening data protection, and improving digital security. The strategy is explicitly identified as a driver behind continuing uptake of SPIM connectivity, Mozambique's newly launched instant-payment rail, which links this product-innovation development directly to the licensing and market-access developments evidenced elsewhere this cycle. The strategy's structure is notable for treating access expansion, data protection, and digital security as a single first-phase package rather than sequencing them, access first, safeguards later. That sequencing choice suggests a policy design in which trust infrastructure is being built concurrently with reach, rather than being deferred until after adoption scales. For product and market-development teams assessing Mozambique, this indicates that new digital-payment products entering the market during 2025-2027 should expect data-protection and digital-security expectations to be live policy priorities from the outset, not a later-stage compliance layer bolted onto an already-scaled product. The strategy's link to SPIM adoption is the clearest concrete manifestation available this cycle of what the inclusion strategy is actually driving in practice: the strategy is credited with continuing to drive uptake of a specific, named piece of payments infrastructure that launched within the same strategy window, giving the strategy's first-phase targets an observable metric to be tracked against rather than remaining a purely qualitative policy commitment. No jurisdiction-specific product-launch or investment detail beyond the strategy itself was evidenced at a confidence level sufficient for inclusion in this module this cycle; the strategy is being treated as the sole material product-innovation development for Mozambique in this baseline. #### Outlook The strategy's first phase runs through 2027, which gives a defined window against which to assess whether access-expansion, data-protection, and digital-security targets are being met concurrently as designed, or whether one dimension outpaces the other two. Product and market-development analysis in subsequent cycles should track whether data-protection and digital-security implementing measures materialise with the same visibility as the access-expansion metrics. **1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-09-08 #### Instant / Real-Time Retail Payment Rails Notice No. 1/GBM/2026 of 25 February 2026 established the Mozambique Instant Payment System, METIX, and approved its regulation. Banco de Moçambique's Governor formally rolled out METIX at a live ceremony at the central bank's Cultural Centre in Matola city in mid-August 2026, marking its move from regulatory approval to live nationwide operation. METIX operates 24/7/365 with instant fund availability, and is accessible via internet banking, mobile apps and USSD. Individual-to-individual, individual-to-business and individual-to-Government interbank transfers over METIX are free of charge, while business-initiated transfers and transfers originated by e-money institutions carry fees set at the discretion of the originating institution. Participating banks may additionally impose lower maximum daily transaction limits than the regulatory ceiling set under Notice No. 1/GBM/2026, calibrated to individual client risk profiles. Access to METIX depends on holding an account with an institution connected to the SIMO network, meaning reach is set by bank and non-bank e-money-institution connectivity to that single national infrastructure rather than by METIX rules alone. #### Outlook METIX's shift to live, fee-free instant retail payments is Mozambique's most consequential payments-infrastructure development this cycle, and its practical reach will continue to be bounded by SIMO network connectivity as the exclusive gate to the rail; usage patterns and any divergence between bank and non-bank e-money-institution participation are worth monitoring as the system matures. **Sources and findings (5)** 1. T1 [https://www.bancomoc.mz/media/unlafn3l/comunicado_sandbox-7%C2%AA-edi%C3%A7%C3%A3o.pdf](https://www.bancomoc.mz/media/unlafn3l/comunicado_sandbox-7%C2%AA-edi%C3%A7%C3%A3o.pdf) retrieved 2026-07-04 2. T3 [https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/](https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/) retrieved 2026-07-04 3. T3 [https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/](https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/) retrieved 2026-07-04 4. T1 [https://www.bancomoc.mz/media/edrlrwxe/communiqu%C3%A9-interoperability-of-mobile-money-operators-in-effect-mkesh-m-pesa-and-e-mola.pdf](https://www.bancomoc.mz/media/edrlrwxe/communiqu%C3%A9-interoperability-of-mobile-money-operators-in-effect-mkesh-m-pesa-and-e-mola.pdf) retrieved 2026-07-04 5. T1 [https://www.bancomoc.mz/en/media/highlights/notice-no-1-gbm-2026-establishes-the-mozambique-instant-payment-system-and-approves-its-regulation/](https://www.bancomoc.mz/en/media/highlights/notice-no-1-gbm-2026-establishes-the-mozambique-instant-payment-system-and-approves-its-regulation/) retrieved 2026-09-08 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-04 Circular No. 01/EMO/2026 of 27 January sets terms for submitting data for statistics on payment means/instruments and financial-access channels, with a 90-day parallel-reporting transition tied to Notice No. 05/GBM/2025 of 21 October. Standing sub-brief · as of 4 July 2026 204 words · last cycle 2026-09-08 #### Consumer Protection & APP Fraud Mozambique has no dedicated financial-consumer protection agency; complaint handling and enforcement for financial-consumer issues sit within Banco de Moçambique itself, rather than with a separate specialised body. This structural point sits alongside a historic conduct-enforcement gap - an industry Board of Ethics that was never established - predating the current Notice-based conduct regime addressed under W1b. Within that BdM-run complaints function, ATM-related disputes dominate the complaint mix: approximately 45% of complaints concern instances where ATM funds were debited but not dispensed, with Millennium BIM and BCI accounting for the largest complaint shares. No dedicated mandatory-reimbursement regime for authorised-push-payment fraud, of the kind operated in the UK by the Payment Systems Regulator, was identified in the sources reviewed for Mozambique. #### Outlook Consumer protection in Mozambique remains structurally concentrated within the prudential regulator rather than distributed to a specialised agency, and the complaint profile - dominated by a specific, identifiable operational failure mode (ATM non-dispense) rather than diffuse fraud typologies - suggests the more tractable near-term intervention would be operational (ATM reliability and reconciliation) rather than a new APP-fraud liability regime. No indication of movement toward either a dedicated consumer agency or an APP-fraud reimbursement rule was found in current sources. no periodic updates on record for this sub-brief ** 1 earlier update recorded under a different module label** An early cycle filed this entry under this module code with a heading naming another subject. Kept for the record; not this module's latest position. Periodic update · new data 2026-09-08 #### Payment Statistics & Regulatory Reporting Circular No. 01/EMO/2026 of 27 January sets terms for submitting data on payment means and instruments and on channels for access to financial services and securities, with a 90-day parallel-reporting transition tied to Notice No. 05/GBM/2025 of 21 October. #### Outlook This backfilled reporting circular is a dashboard-tier infrastructure item; the 90-day parallel-reporting transition window is the operative near-term milestone to track. **Sources and findings (4)** 1. T1 [https://www.bancomoc.mz/en/educational/financial-consumer-portal/market-conduct-and-consumer-protection/](https://www.bancomoc.mz/en/educational/financial-consumer-portal/market-conduct-and-consumer-protection/) Applies beyond this jurisdiction (World Bank) retrieved 2026-07-04 2. T3 [https://360mozambique.com/economy/banking/bank-of-mozambique-fines-nine-financial-institutions-for-breaches-of-regulations/](https://360mozambique.com/economy/banking/bank-of-mozambique-fines-nine-financial-institutions-for-breaches-of-regulations/) retrieved 2026-07-04 3. T2 [https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Mozambique-Diagnostic-Review---Banking-and-Non-Banking-Credit-Institutions---V-II.pdf](https://responsiblefinance.worldbank.org/content/dam/documents/responsible-finance/Mozambique-Diagnostic-Review---Banking-and-Non-Banking-Credit-Institutions---V-II.pdf) retrieved 2026-07-04 4. T1 [https://www.bancomoc.mz/en/areas-of-expertise/supervision/conduct/](https://www.bancomoc.mz/en/areas-of-expertise/supervision/conduct/) retrieved 2026-07-04 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/mozambique/#sec-dom-D7) Confirmed confirmed 2026-07-04 Sentinel position: Mozambique was FATF grey-listed October 2022-October 2025 for AML/CFT deficiencies, completing all 26 action-plan items before being delisted alongside South Africa, Nigeria and Burkina Faso. New AML/CFT laws (14/2023, 15/2023) replaced the prior 2022 regime, GIFiM remains the financial-intelligence unit, and BdM has imposed transaction-limit tiers on e-money institutions given an assessed 'high' terrorism-financing threat level in that sector. Standing sub-brief · as of 4 July 2026 185 words · last cycle 2026-09-28 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed; in keeping with WPM methodology, the items below are carried on that provenance without original illicit-finance analysis performed here, and readers should consult Sentinel.gi directly for the underlying analytical treatment. Mozambique was removed from the FATF grey list in October 2025 after completing all 26 items of its action plan; the FATF plenary unanimously delisted Mozambique alongside South Africa, Nigeria and Burkina Faso. Separately, Banco de Moçambique has imposed tiered (Level I-III) transaction and balance limits on electronic money institutions since April 2024, citing a "high" terrorism-financing threat assessment linked to the movement of funds into areas of active terrorist threat via rural IME concentration. #### Outlook The FATF delisting is a material, positive change to Mozambique's cross-border financial-crime risk profile and interacts directly with the correspondent-banking access questions addressed under W12. The IME transaction-limit tiers remain in force independent of that delisting, reflecting a threat assessment specific to rural fund-movement patterns rather than the broader grey-list status; for further analytical depth on either item, see the corresponding Sentinel.gi reporting and FIM's cross-monitor treatment. Periodic update · new data 2026-09-29 #### AML/CFT & Financial Crime Mozambique's AML/CFT standing improved materially over the past year on two internationally recognised list-based measures. FATF removed Mozambique from its list of jurisdictions under increased monitoring effective 24 October 2025, and the EU subsequently removed Mozambique from its list of high-risk third countries, with that change taking effect 29 January 2026. This intelligence is carried into this brief from the Sentinel feed as a confirmed, high-confidence development rather than independently re-analysed here. For payment-systems operators and their banking counterparties, the practical significance of this delisting lies chiefly in its effect on enhanced-due-diligence obligations: counterparties whose EDD regimes are keyed to FATF or EU list status faced mandatory enhanced scrutiny of Mozambique-linked relationships while the listings were in force, and that specific trigger no longer applies now that both listings have been lifted. This is an operating-environment fact relevant to payment-systems risk assessment; it is not a compliance-screening conclusion for any individual counterparty, and it should not be read as a statement that all illicit-finance risk associated with Mozambican payment channels has been resolved. #### Outlook Whether the delisting translates into observable easing of correspondent-banking de-risking pressure on Mozambican payment institutions is the key item to watch, though this effect has not yet been directly evidenced in bank-level data this cycle. This module treats the delisting as an input to the payments operating environment; readers seeking the underlying AML/CFT architecture and residual technical-compliance findings should consult the financial-integrity monitor's own AML/CFT domain coverage. **Sources and findings (6)** 1. T3 sentinel.gi/mozambique-bdm-aml-fines 2. T? FIM (sentinel.gi) per-JID baseline profile — Mozambique — Mozambique's AML/CFT regime is anchored in its Money Laundering and Terrorist Financing Law, supervised by Banco de Moçambique and the national FIU (GIFiM). Mozambique strengthened the effectiveness of its AML/CFT regime to meet the commitments in its action plan regarding the strategic deficiencies that the FATF identified in October 2022, resulting in removal from the FATF grey list in October 2025, though capacity gaps persist in BO collection, FIU resourcing, and supervision of extractive and NPO sectors. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-005) — Enforcement: Swiss Federal Criminal Court — UBS Group AG (as successor to Credit Suisse) 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: capacity-deficit ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-04 BM re-based the rules governing connection to the national Single Payments Network (Rede Única de Pagamentos, operated over the SIMO infrastructure) via Aviso No. 2/GBM/2026 of 2 June 2026, revoking the prior 2015 framework. SIMO remains the exclusive, nationwide Single Network Operator (Sociedade Interbancária de Moçambique) used by credit institutions and financial companies, and is the connectivity gate for METIX access. Standing sub-brief · as of 4 July 2026 184 words · last cycle 2026-09-08 #### Correspondent Banking, Settlement & Access Mozambique's correspondent-banking access is constrained by the broader global de-risking trend: no US banks are physically present in the country, and global correspondent-banking relationships fell by roughly 15-20% between 2010 and 2023, with that contraction concentrated in Africa. USD-denominated transactions therefore rely on a correspondent bank list rather than direct US banking presence. This module's analytical spine is the asymmetry between bank access to correspondent networks and the comparatively thinner access available to non-bank payment institutions, though current sources speak primarily to the bank-level picture. SADC-RTGS (see W5) provides a partial structural offset to this correspondent-banking pressure, giving Mozambique a regional settlement channel that does not depend on bilateral USD correspondent relationships for intra-SADC flows. #### Outlook Mozambique's October 2025 FATF grey-list delisting (see W11) should, over time, ease some de-risking pressure specific to Mozambique's own risk classification, though the broader Africa-wide correspondent-banking contraction is a structural trend operating independently of any single country's FATF status. SADC-RTGS and any future PAPSS/COMESA REPSS interlinking remain the more durable offsets to correspondent-access constraints than a change in any one jurisdiction's grey-list status. Periodic update · new data 2026-09-08 #### Correspondent Banking, Settlement & Access Aviso No. 2/GBM/2026 of 2 June 2026 sets new rules for connection to the Single Payments Network, revoking Aviso No. 2/GBM/2015 of 22 April. SIMO remains the exclusive, nationwide Single Network Operator used by credit institutions and financial companies to manage electronic transactions. METIX's access is gated on holding an account with an institution connected to that same SIMO network, meaning that both bank and non-bank e-money institutions reach the instant-payments rail only through this single shared connectivity layer. #### Outlook The module's analytical spine is the access asymmetry between banks and non-bank e-money institutions in reaching Mozambique's settlement infrastructure: connection to SIMO, not participation in any single scheme, is what determines whether an institution's customers can reach METIX and the wider national payments network, and Aviso No. 2/GBM/2026's re-based connection rules are the mechanism to watch for any change in that access calculus. **1 earlier distinct update(s)** Periodic update · new data 2026-09-05 #### Correspondent Banking, Settlement & Access Mozambique's settlement structure operates on a clear bank-versus-non-bank access asymmetry that is the analytical spine of this module. SIMO operates as the national interbank settlement infrastructure, now carrying the newly launched Instant Payment System established under Notice 1/GB/2026. Separately, Banco de Moçambique's Notice 7/GBM/2024 establishes tiered mobile-money transaction and balance limits across Level I to Level III tiers, with the upper tier reaching up to MZN3 million for micro and small-business mobile-money accounts, functioning as an AML/CFT risk control layered onto the non-bank side of the settlement structure. This creates a two-track access model: bank-operated settlement through SIMO, now benefiting from 24/7 instant-payment infrastructure and governed by the individual and legal-entity daily caps described elsewhere, and mobile-money settlement, which is governed instead by tiered balance and transaction limits designed primarily as a risk-management control rather than as a corridor-capacity measure. The two tracks are not fully separate in practice, since mobile-money operators ultimately settle through the same underlying banking and interbank infrastructure that SIMO provides, but the regulatory treatment of each track differs meaningfully: banks operate under transfer caps tied to instant-payment infrastructure, while mobile-money accounts operate under tiered AML/CFT-oriented balance limits. #### Outlook The structural question to watch is whether the bank-operated instant-payment rail and the tiered mobile-money settlement structure move toward closer regulatory convergence, particularly as bank/mobile-money commercial partnerships such as the M-Pesa/Absa MOU push technical integration further. Any regulatory update harmonising the two tiers' limit structures would be a significant correspondent-and-settlement development to track in a future cycle. **Sources and findings (4)** 1. T1 [https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGS](https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGS) retrieved 2026-07-04 2. T3 [https://www.trade.gov/country-commercial-guides/mozambique-trade-financing](https://www.trade.gov/country-commercial-guides/mozambique-trade-financing) retrieved 2026-07-04 3. T4 [https://www.trustsphere.ai/post/the-de-risking-dilemma-balancing-correspondent-banking-access-with-financial-crime-controls](https://www.trustsphere.ai/post/the-de-risking-dilemma-balancing-correspondent-banking-access-with-financial-crime-controls) retrieved 2026-07-04 4. T2 [https://www.boz.zm/payment-systems/regional-payment-systems](https://www.boz.zm/payment-systems/regional-payment-systems) retrieved 2026-07-04 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-04 Mozambique's payments/fintech commercial-intelligence flow over the trailing 12 months is limited but active: South African B2B lending-as-a-service fintech Kuunda expanded into Mozambique and secured a US$7.5m pre-Series A round (continent-wide, including Mozambique) in late 2025; savings-group fintech Roscas secured investment from Renew Capital; and the domestic startup base remains small (13 fintech companies per Tracxn, only 1 funded, 1 acquisition). Standing sub-brief · as of 4 July 2026 210 words · last cycle 2026-10-11 #### Commercial Intelligence (M&A, Investment & Product) Kuunda expanded into Mozambique and secured a US$7.5 million pre-Series A funding round in late 2025, intended to accelerate the company's growth across Africa and the Middle East; Mozambique is named as one of several expansion markets in that continent-wide round rather than the sole destination for the capital. Separately, Mozambican fintech Roscas secured investment from Renew Capital; the amount was not publicly disclosed in reporting reviewed this cycle. A third, development-finance-adjacent event is included for completeness: FINOVA, the Innovative Financing for Agribusiness Project, rolled out a Banco de Moçambique-supported agribusiness credit line backed by German development finance - a EUR 33.5 million KfW-funded facility split between EUR 20 million in working capital and EUR 13.5 million in investment capital, led by the Ministry of Planning and Development. #### Outlook Mozambique's domestic fintech/startup base remains nascent and telecom/bank-linked rather than venture-driven, with a small tracked population of startups and comparatively few funded or acquired entities. The Kuunda and Roscas events indicate external and Africa-focused investor interest is beginning to reach Mozambique specifically, rather than treating it purely as an extension market, but the private-company signal depth for Mozambique remains thin relative to more heavily VC-covered African fintech hubs, a standing gap noted for future cycles. Periodic update · new data 2026-10-11 #### Commercial Intelligence & Fintech The principal commercial-intelligence event for Mozambique this cycle is the Bank of Mozambique's grant of a payment-services-provider licence to PawaPay, announced and completed on 8 October 2026. The licensing arrangement is best characterised as a licensing agreement between PawaPay, acting as licensee, and the Bank of Mozambique; no transaction value has been publicly disclosed, consistent with the regulatory rather than acquisitive nature of the event. The licence enables PawaPay to begin commercial operations immediately, with merchant onboarding reported to begin in the days immediately following the grant. Commercial reporting frames the event against the scale of Mozambique's mobile-money market, citing a wallet base in the tens of millions, substantially larger than the country's banked population. PawaPay's technical integration is reported as live for M-Pesa and enabled for e-Mola payouts, while Tmcel's mKesh wallet remains outside the connected set at the time of licensing. This partial-connectivity picture suggests the commercial rollout is being completed in phases rather than as a single simultaneous market launch across all major mobile-money rails. The event is corroborated across independent commercial-press sources, lending reasonable confidence to the fact of the licence grant and its immediate operational effect, even though no Bank of Mozambique primary notice confirming the grant has been located. As a discrete, dated commercial event rather than a structural market-wide trend, this licensing sits squarely within this module's remit; the broader structural question of how non-bank PSP entry is reshaping Mozambique's payments market more generally is a separate, thematic consideration not addressed by this single event. #### Outlook The near-term commercial signal to track is whether PawaPay completes integration with Tmcel's mKesh wallet, which would complete its connectivity across Mozambique's major mobile-money rails and meaningfully expand its addressable merchant-onboarding base. Confirmation of the licence grant directly from a Bank of Mozambique primary notice, rather than solely from commercial press, remains an open item for future verification. **1 earlier distinct update(s)** Periodic update · new data 2026-09-05 #### Commercial Intelligence & Fintech The discrete commercial event this cycle is the memorandum of understanding signed at FACIM 2026 between M-Pesa, operated by Vodacom, and Absa Bank Mozambique, linking the Paga Fácil merchant service to Absa bank accounts. This is classified as a partnership-restructuring event under an announced status, with the deal's financial terms not publicly disclosed. As a discrete commercial event, it is distinct from any broader structural industry-consolidation narrative: it is a specific, dated partnership announcement between two named parties rather than a market-wide trend. No additional discrete commercial events, such as funding rounds, acquisitions, or product launches beyond the instant-payment infrastructure covered under Payment Corridor Dynamics, were identified for Mozambique this cycle. #### Outlook The next commercial-intelligence milestone to watch is whether the M-Pesa/Absa memorandum of understanding converts into an announced operational product launch, at which point financial and technical terms may become clearer. Any follow-on funding, investment, or additional partnership announcement involving Mozambican payment-sector participants would also be tracked here in a future cycle. **Sources and findings (4)** 1. T3 [https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/](https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/) retrieved 2026-07-04 2. T3 [https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/](https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/) retrieved 2026-07-04 3. T3 [https://tracxn.com/d/explore/fintech-startups-in-mozambique/yCpaKPFTlkZqAiiUSM-AykzOdW_XbrZPYNwVJfO4-8A#top-companies](https://tracxn.com/d/explore/fintech-startups-in-mozambique/yCpaKPFTlkZqAiiUSM-AykzOdW_XbrZPYNwVJfO4-8A#top-companies) retrieved 2026-07-04 4. T3 [https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/](https://mena-fintech.org/news/mozambique-turns-to-fintech-to-expand-financial-inclusion/) retrieved 2026-07-04 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Mozambique| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 1 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 72 finding(s), 160 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).